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AHPA submitted a comment letter on: CMS-1808-P; Medicare and Medicaid Programs and the Children’s Health Insurance Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2025 Rates; Quality Programs Requirements; and Other Policy Changes Click here for the full comment letter. Below are some key takeaways.

• Ensure hospital payment updates reflect the actual cost of providing care: AHPA argues that CMS’s proposed 2.6 percent payment increase does not adequately account for hospitals’ rising labor, supply, and care-delivery costs. It urges CMS to adapt its payment methodology to changing market conditions to prevent continued underpayment from affecting hospital stability, care quality, and timely patient access.
• Advance health equity by recognizing the cost of addressing patients’ social needs: AHPA supports reclassifying housing-related Z codes as complications or comorbidities because this better reflects the cost of treating patients experiencing housing instability. It also recommends that CMS expand reimbursement to additional health-related social-needs domains, including food insecurity and other factors that increase utilization and care costs.
• Revise the mandatory TEAM model to provide fair, clinically appropriate accountability: AHPA recommends that CMS improve TEAM’s benchmarking and risk-adjustment methodology, replace arbitrary target-price adjustments with clinically informed pathways, and tailor quality measures to the patients and surgical episodes included in the model. It also recommends giving hospitals at least 18 months after publication of the final rule to prepare and allowing existing Hospital IQR reporting to satisfy TEAM’s social-needs reporting requirements.
• Modernize hospital quality reporting while avoiding duplicative or punitive requirements: AHPA supports CMS’s transition toward electronic clinical quality measures and several proposed patient-safety, age-friendly care, falls, respiratory failure, and failure-to-rescue measures. However, it recommends clearer measure specifications, a phased transition before new measures become mandatory, and removal of duplicative Patient Safety Indicator measures. AHPA also opposes using Medicare Conditions of Participation to require respiratory-illness reporting, recommending that CMS encourage reporting through quality or payment programs instead.
• Improve maternal health without imposing inflexible requirements that could reduce access to obstetric care: AHPA supports CMS’s goal of improving maternal outcomes but cautions against restrictive, one-size-fits-all obstetric Conditions of Participation or staffing standards that could further strain rural and underserved hospitals and contribute to maternity-unit closures. It recommends using outcome-based quality measures, developing a maternity-specific patient experience survey, increasing prenatal and postnatal reimbursement, and considering a blended payment model that supports continuity of care from pregnancy through the postpartum period.